Etteplan Oyj

The role of the administrative, management and supervisory bodies

Reference: pages 35-36.

Etteplan operates under a one-tier governance model: the Board consists entirely of non-executive members (0 executive, 6 non-executive), with the CEO and Management Group running day-to-day operations. Board gender diversity: 50% female / 50% male; 66.7% (4 of 6) of Board members are independent.

Sustainability oversight roles (page 35):

• Board of Directors holds ultimate accountability for sustainability oversight, including approval of ESG targets and the Sustainability Report.
• Audit Committee monitors integration of sustainability risks into financial and operational controls and validates reporting processes.
• Management Group oversees implementation of sustainability objectives and "is also the most senior level in the organization accountable for implementing policies adopted to manage material sustainability matters."
• ESG Steering Group leads operational execution of the Sustainability Agenda, including target setting, resource allocation, EU Taxonomy reporting and identification of material IROs.

Reporting line: ESG Steering Group -> Management Group -> Board of Directors and Audit Committee. Employees are not directly represented on the Board; their interests are considered through management reporting and engagement mechanisms.

Information provided to and sustainability matters addressed by governance bodies

Reference: page 36.

Governance bodies receive regular updates on material sustainability IROs, due diligence implementation and the effectiveness of related policies, actions, metrics and targets, "through presentations and written briefings during scheduled meetings and ad hoc sessions when material changes occur."

Frequency in 2025:

• Board of Directors — "addressed strategic sustainability matters eight times during 2025 in its meetings."
• Audit Committee — "Addressed sustainability reporting and the integration of sustainability risks into internal control systems five times during 2025."
• Management Group — met monthly to review ESG targets and progress on sustainability initiatives.
• ESG Steering Group — met quarterly and as needed to guide implementation of the Sustainability Agenda and EU Taxonomy reporting.
• ESG Task Force — convened on an ad hoc basis to support data collection and CSRD reporting preparation.

Integration of sustainability-related performance in incentive schemes

Reference: page 37 (E1 chapter cross-references this at page 57).

"In 2025, the company did not have an incentive scheme that included sustainability targets." During the year, the Board approved a new incentive scheme for 2026-2028 that "will include also sustainability targets as part of performance evaluation," so sustainability metrics enter remuneration policy from 2026 onward. In 2025 no part of variable pay was linked to sustainability targets; "More details will be shared once the new scheme is in effect."

Statement on due diligence

Reference: page 37.

Etteplan provides a due-diligence core-elements table mapping each element to the sections of the Sustainability Statements that disclose it (GOV-4_01):

Risk management and internal controls over sustainability reporting

Reference: page 37.

Etteplan applies "structured risk management and internal control processes... aligned with ISO 31000 principles and our Enterprise Risk Management (ERM) framework," covering the reporting cycle "from data collection to publication."

Main risks identified: limited availability of value chain data; accuracy of input data and estimation results; completeness under time pressure; regulatory interpretation and system integration challenges.

Mitigations: clear data-point ownership; prioritising resources for material sections; requiring evidence/documentation for data integrity; multi-level internal reviews; digital tools to reduce manual errors. The Sustainability Specialist maintains a risk register with oversight from the ESG Steering Group, reviewed annually; the ESG Steering Group escalates significant issues to the Management Team and Audit Committee.

Strategy, business model and value chain

Reference: pages 38-39.

Etteplan has 3,777 employees (2025) across Finland (47.18%, 1,782), Scandinavia (18.45%, 697), Central Europe (23.83%, 900), China (10.51%, 397) and the USA (0.03%, 1); Group revenue was EUR 361.4 million.

Three service areas: Engineering Solutions (design/engineering of machinery, equipment and plants; linked to material impacts on resource efficiency); Software and Embedded Solutions (digitalization, connectivity and intelligence for machinery); Technical Communication and Data Solutions (technical documentation, renamed in January 2025 "to reflect the growing importance of data in our strategy").

Markets are primarily Europe (Nordics, Central Europe), with a growing presence in China and some North America operations, serving Manufacturing, Automotive, Healthcare & Medical Devices, Aerospace & Defense, and Energy & Power Generation.

Interests and views of stakeholders

Reference: pages 42-43.

Key stakeholders: employees, customers, shareholders, investors, suppliers and business partners, plus educational institutions, students, media, industry organizations, authorities and NGOs.

Engagement channels: meetings, events, surveys, audits, feedback channels, reporting mechanisms and working groups; Etteplan is a founding member of Technology Industry Employers of Finland and a member of the Swedish Federation of Consulting Engineers and Architects and SVEAT.

Stakeholder input (management interviews, workshops, employee surveys, partner-expectation studies) is integrated into the Double Materiality Assessment; the 2023-2024 update to the Sustainability Agenda involved the Board of Directors, Management Group and Audit Committee. Each ESRS topic was assessed for impacts, risks and opportunities "over the short, medium, and long term," feeding the 2025 Decision-Making Framework.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 34, 43-44 (materiality outcome table).

The 2025 DMA identified a short list of material IROs (page 34):

"All material impacts, risks, and opportunities identified are covered by ESRS Disclosure Requirements. No additional entity-specific disclosures are required" (page 34). The 2025 DMA also removed ESRS S2 (workers in the value chain) as material, reflecting Etteplan's "business model as a technology service company with limited procurement and no manufacturing operations" (page 34).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 43-44.

Five-phase methodology: (1) Understanding context — analyse current state, map value chain, engage stakeholders; (2) Identification — actual/potential impacts, risks and opportunities across operations and value chain; (3) Assessment — score impact materiality (severity, likelihood) and financial materiality (magnitude, likelihood); (4) Prioritization — rank via a materiality matrix; (5) Validation — review and approval by ESG Steering Group, Management Group, Audit Committee and Board of Directors.

Materiality threshold: score >= 12 for either impact or financial materiality, considering short-, medium- and long-term horizons. Additional sources: ENCORE, Climate Risk Scenarios, HRDD. External expertise provided by Greenstep Oy, supported by ENCORE and climate-scenario analyses. Compared to the prior period, Etteplan "refined its methodology, expanded scope to include value chain impacts, improved stakeholder engagement, and strengthened governance oversight."

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: page 44. No dedicated page-referenced content-index table (an Appendix-2-style DR/page concordance) was found in this report; classification below is drawn from the report's own section headings/page numbers (per-chapter table of contents) and body text, since no formal IRO-2 concordance table exists.

"Etteplan's Sustainability Statements has been prepared in full alignment with the European Sustainability Reporting Standards (ESRS) and the outcome of our Double Materiality Assessment (DMA)."

Topics prioritised for disclosure: those scoring >=12 ("Critical") in the DMA. Topics scoring lower were "considered but not prioritized for disclosure." The report states: "Etteplan evaluated its impacts, risks, and opportunities related to E2 Pollution, E3 Water and Marine Resources, E4 Biodiversity, and E5 Resource Use and Circular Economy, based on the best available internal information and through stakeholder engagement," but these were not prioritised.

Etteplan also states it "assessed whether any ESRS data points derive from other EU legislation... and confirms that none apply for this reporting period" in terms of applicability generally, though page 45-49 does carry a list of cross-cutting datapoints derived from SFDR/Pillar 3/Benchmark Regulation/EU Climate Law, marking only E1-related rows "Is material topic."

Transition plan for climate change mitigation

Reference: page 58 ("ESRS E1-1 - How we plan to reduce emissions and adapt to climate change").

Etteplan's transition plan "supports the goals of the Paris Agreement, including limiting global warming to 1.5C and achieving climate neutrality by 2050." Target: reduce Scope 1, 2 and 3 GHG emissions by 42% by 2030, 2022 base year, aligned with the SBTi pathway and a 1.5C scenario, set following a 2023 DMA.

Levers: reducing office energy consumption, low-carbon commuting/travel, low-carbon procurement; planned actions include LED lighting upgrades, automated ventilation, bio-based aviation fuel, and supplier preference for carbon-reduction commitments. Etteplan is also expanding energy-efficient engineering, digitalization for resource optimization, and low-carbon technology services for clients.

Financial resources: modest OpEx — "EUR 291-1,973 for certified green energy and approximately EUR 39,200 for low-carbon business travel"; no significant CapEx currently required. "Etteplan's qualitative assessment found no locked-in GHG emissions from key assets or products." Not excluded from EU Paris-aligned benchmarks. Plan approved by Etteplan Group's Management on December 17, 2024; overseen by the ESG Steering Group with annual reviews.

Identification of climate-related risks and scenario analysis

Back-filled from the report's ESRS 2 IRO-1 climate-specific subsection (page 60), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against (the report applies the ESRS 'quick-fix' reliefs under EU Delegated Regulation (EU) 2025/4812, page 34).

Etteplan classifies material climate risks as physical (acute: heat waves, floods, storms, cyclones; chronic: temperature variability, water stress, coastal erosion) and transition (regulatory, technological, market/reputational, cybersecurity) (page 58-60).

Scenarios used: physical risk — SSP1-2.6 (low emissions) and SSP5-8.5 (high emissions), from IPCC/NGFS; transition risk — RCP 1.9 and RCP 2.6. Exposure/sensitivity was assessed across "eight operating countries and 93 office locations," using workforce distribution, leased office sites and service-delivery dependencies (page 60). Time horizons: short (<1 year), medium (1-5 years), long (>5 years). No explicit global-average-temperature projection per scenario is stated — that omission is a finding worth noting. Assumptions cited: policy trends, macroeconomic trends, energy mix, technology deployment, and stakeholder expectations.

Resilience in relation to climate change

Back-filled from the report's ESRS 2 SBM-3 climate-specific subsection (page 58), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The resilience analysis, conducted in October 2025 by a cross-functional working group with external tools and expert judgement, covered "Etteplan's entire value chain at a high level, including its own operations, upstream service purchases, and downstream service delivery... No material risks were excluded."

Results: under the low-emissions scenario, transition risks are high (regulatory pressure, stakeholder expectations) but present opportunities to expand climate-smart services; under the high-emissions scenario, physical risks dominate, with chronic risks needing deeper long-term integration. "Etteplan demonstrates strong operational resilience in the short to medium term and strategic alignment with Net Zero 2050 ambitions."

Ability to adapt: short-term remote-work/IT redundancies; medium-term portfolio evolution toward low-carbon engineering; long-term alignment with Net Zero 2050/SBTi.

Uncertainty: "Constraints included the absence of geospatial coordinates, though location-specific hazard profiles were incorporated." Etteplan "plans to integrate climate risk analysis into its Enterprise Risk Management (ERM) framework in future cycles."

Policies related to climate change mitigation and adaptation

Reference: page 61.

"Etteplan is currently in the process of formalizing" dedicated climate policies (E1.MDR-P). Climate actions and targets are detailed in the E1-3 and E1-4 sections respectively, and are embedded through the Emission Reduction Guideline (2025), which "operationalizes strategic objectives into actions across Scope 1, 2, and 3 categories."

Actions and resources in relation to climate change policies

Reference: page 61.

Actions and targets for climate change mitigation are detailed under E1-3/E1-4. As of 2025, Etteplan had no investments in coal, oil, or gas-related activities; the company promotes low-carbon procurement and travel policies and aims to increase taxonomy-eligible/-aligned revenue.

Key decarbonization levers: reducing office energy consumption, promoting low-carbon commuting and business travel, low-carbon procurement. Planned actions: LED lighting upgrades, automated ventilation, bio-based aviation fuel, supplier preference for carbon-reduction commitments. Etteplan is expanding energy-efficient engineering, digitalization for resource optimization, and low-carbon technology services. Progress in implementation: the Emission Reduction Guideline (2025) and "improved GHG calculation methods" to ensure accurate emissions data.

Targets related to climate change mitigation and adaptation

Reference: page 62.

Target: reduce Scope 1, 2 and 3 GHG emissions by 42% by 2030, against a 2022 base year, aligned with the SBTi pathway (1.5C scenario). "Targets are gross (excluding removals, credits, and avoided emissions) and consistent with GHG inventory boundaries," "in line with ESRS E1-6 requirements." The 2022 baseline "remains unchanged to ensure comparability over time"; energy consumption "has remained consistent across 2023-2025 compared to 2022."

Progress (Total GHG emissions, market-based, tCO2e): base year 2022 14,427.6; 2024 15,697.0; 2025 12,926.2 (table figure; narrative cites 12,929.3), a -18% year-on-year change against the 2030 target of -42% from base year.

If significant changes to targets or reporting boundaries arise, Etteplan "will disclose how any new baseline value affects the revised targets, their achievement, and the presentation of progress."

Energy consumption and mix

Reference: page 64. Scope note: covers offices in Finland, Poland, Sweden, Germany and the Netherlands; "Offices in China, Denmark, and the USA are excluded from this assessment."

High climate impact sectors (page 64-65): "while Etteplan's activities are not directly high climate impact specified, 51.6% of Etteplan's activities are enabling activity for high climate impact sector (taxonomy-eligible or -aligned)." Energy intensity from those activities: 17.9 MWh/M-EUR net revenue (2024) -> 17.5 (2025), a -2% change, against net revenue from those activities of EUR 179.8m (2024) / EUR 186.4m (2025) out of EUR 361.0-361.4m total.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 65-66.

"In 2025, our market-based carbon footprint was 12,929.3 tCO2e (15,697.0 in 2024), indicating a decrease compared to the prior year." Table figures show total market-based emissions of 14,427.6 tCO2eq (2022 base), 15,697.0 (2024), 12,926.2 (2025) — a -18% year-on-year change.

Boundary: "For 2025, Etteplan Oyj, Finland, and Sweden are fully accounted for under Scopes 1-3. Poland, Germany, and the Netherlands are fully included for Scopes 1 and 2, while Scope 3 coverage in these countries is limited to employee commuting and fuel- and energy-related activities." Categories 2, 8, 10, 13, 14 not assessed/no activity identified; category 15 excluded for now. "Metrics presented in this section have not been externally validated."

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 62 (E1-4 targets section).

Etteplan reports a nil position rather than a quantified removals/credits figure. Its emission-reduction targets are stated as "gross (excluding removals, credits, and avoided emissions)," and the report states explicitly: "Targets exclude GHG removals, carbon credits, and avoided emissions, in line with ESRS E1-6 requirements." No GHG removal projects or carbon-credit-financed mitigation projects are described anywhere in the E1 chapter (pages 58-66).

Policies related to own workforce

Reference: page 75.

"Etteplan has established a comprehensive policy framework to manage material impacts, risks, and opportunities related to its own workforce," addressing working conditions, health and safety (psychosocial risk), equal treatment and opportunities, training and skills development, and workforce diversity.

The global Quality, Environment, Health and Safety (QEHS) Policy underpins occupational health and safety, including stress management and workload monitoring, complemented by country-specific guidelines. The Equal Opportunity & Non-Discrimination policy and DEI Policy address gender equality and pay equity and promote diversity across age and cultural background. Etteplan's Code of Conduct embeds human-rights commitments aligned with the UN Guiding Principles on Business and Human Rights and relevant ILO Conventions, including "non-discrimination, fair working conditions, freedom of association, and the right to collective bargaining." Respect for human/labor rights is integrated into ERM and Human Rights Due Diligence (HRDD) processes.

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 77.

Engagement channels include "legislated dialogue meetings held quarterly or as needed," the annual FuturETTE employee survey (72% response rate in 2025), Occupational Health and Safety (OHS) Committee meetings, and monthly Happy DEIs sessions. Topics covered: health and safety, psychosocial workload, diversity, gender equality, pay transparency; training/career-development dialogue occurs annually via each employee's Personal Development and Performance Plan (PDP).

Operational responsibility sits with the Senior Vice President, Human Resources, supported by the SVP Marketing and Communications; the CEO ensures outcomes inform strategic decisions. Effectiveness is assessed via the FuturETTE survey, dialogue/OHS-committee participation, DEI-forum feedback, and an Equity & Inclusion Index. "Etteplan does not have a Global Framework Agreement but aligns its engagement processes with... the UN Global Compact principles and relevant labor rights conventions."

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 78.

Remediation follows structured processes defined in the Code of Conduct: "corrective actions, dialogue with affected individuals, and other measures appropriate to the impact," with effectiveness assessed through timely resolution, recurrence monitoring and worker feedback; the HRDD process supports remediation.

Channels: direct dialogue with supervisors/leadership; engagement with employee representatives per local legislation; a secure, anonymous whistleblowing tool (third-party provider) compliant with the EU Whistleblowing Directive, available in multiple languages, with phone/in-person options for employees without digital access.

Grievance escalation is tiered by severity: HR-level issues to line management/HR; serious issues investigated by trained staff; significant issues to senior leadership; crisis issues to the Audit Committee. A strict non-retaliation policy applies; awareness is reinforced through onboarding and mandatory Code of Conduct eLearning.

Taking action on material impacts on own workforce

Reference: page 78.

Actions map to the four material S1 sub-topics (Table S1-4, page 78):

Remedies for actual impacts include counselling, workload adjustments and confidential grievance handling. Effectiveness is tracked through KPIs, the FuturETTE survey, gender-balance metrics and training completion rates, integrated into HRDD and ERM.

Targets related to own workforce

Reference: page 79.

Key targets (Table S1-5):

• Health and safety — "Achieve zero workplace accidents, achieve zero workplace harassment and inappropriate cases. Enhance Psychosocial Safety"; a dedicated psychosocial-workload management programme starts in 2026.
• Gender equality and equal pay — reduce the gender pay gap and increase the proportion of women employed, benchmarked against STEM graduate percentages in operating countries.
• Training and skills development — 100% completion of annual PDP discussions and Code of Conduct training for all employees.
• Diversity — maintain/strengthen the Equity & Inclusion (E&I) Index score in the FuturETTE survey, "continuing to exceed the long-term goal of 4 out of 5 by 2026."

Targets apply globally, reviewed annually, with ultimate accountability at Board level; workforce representatives were consulted via OHS committees, equality discussions and PDP feedback loops.

Characteristics of the undertaking's employees

Reference: page 80.

Headcount at 31.12.2025: 3,777 employees (31.12.2024: 3,803) — male 2,811 (2024: 2,852), female 966 (2024: 949), other 0 (2024: 2).

By country (2025 / 2024): Finland 1,782 / 1,882 (47.18% / 49.5%); Sweden 685 / 708 (18.14% / 18.6%); Germany 617 / 477 (16.34% / 12.5%); China 397 / 397 (10.51% / 10.4%); Poland 168 / 187 (4.45% / 4.9%); Netherlands 115 / 136 (3.04% / 3.6%); Denmark 12 / 15 (0.32% / 0.4%); United States 1 / 1 (0.03% / 0.03%).

Data source: the global HR system Sympa. "The employee headcount reported under ESRS S1-6 is fully aligned with the number disclosed in Etteplan's financial statements."

Diversity metrics

Reference: page 82.

Top management (Etteplan's Global Management Group, 9 members): male 6 (55.6%), female 3 (33.3%).

Age distribution of employees:

(A further row for "Under 30" at 9 employees / 0.2% appears in the extracted table but its label is ambiguous in the source text — flag for a page check against the PDF.)

Health and safety metrics

Reference: page 82.

"Etteplan ensures comprehensive health and safety management across its operations, with 100% of the workforce covered by systems based on legal requirements and recognized standards or guidelines." In 2025 there were no fatalities among Etteplan's own workforce or other workers on Etteplan's sites. "The company recorded five work-related accidents, resulting in a recordable accident rate of 0.86 per million hours worked."

Compensation metrics (pay gap and total compensation)

Reference: page 83. Data covers full-time active employees as of 31 December 2025, from the global HR system Sympa combined with local payroll data.

Gender pay gap: 13% (2025) vs. 14% (2024). "Gender pay gaps by country are weighted according to headcount. The calculations do not take into account factors such as education, job level, or job demands." Etteplan notes "the technology sector generally has a lower representation of women in leadership positions, which influences overall pay gap figures," and states compensation equality between genders as one of its Sustainability Agenda targets.

Annual total remuneration ratio (CEO-to-median-employee): 11.1 (2025) vs. 11.8 (2024).

Incidents, complaints and severe human rights impacts

Reference: page 83.

"No fines, penalties, or compensation related to incidents, complaints, or severe human rights issues occurred during the reporting period. Etteplan did not identify any severe human rights impacts connected to its workforce."

Business conduct policies and corporate culture

Reference: pages 85-87.

The 2025 DMA identifies Etteplan's "strong corporate culture" as a material actual positive impact and "the risk of corruption and bribery - which may result from insufficient awareness and inadequate internal control procedures" as a material potential negative impact/financial risk (page 86).

The Code of Conduct is the central policy, covering ethical behaviour, anti-corruption (zero-tolerance, backed by training/controls/reporting), corporate culture, and whistleblowing; approved by the Board, overseen by the President & CEO. Reinforced by the Happy DEIs initiative (2022, formalized as a DEI Policy in 2025), a Supplier Code of Conduct, and the FuturETTE survey. Training: mandatory Code of Conduct eLearning, repeated every two years.

Whistleblowing: a secure, anonymous channel operated by third-party provider Falcony, compliant with the EU Whistleblower Directive (2019/1937), tiered (levels 1-4) by severity; handled by a designated team including the SVP HR, CFO and Finnish HR Director. "At this time, no specific functions have been identified as being at heightened risk for corruption or bribery," based on operations, existing controls and prior risk indicators.

Prevention and detection of corruption and bribery

Reference: page 88.

"Etteplan has a zero-tolerance policy for bribery, corruption, and money laundering, as outlined in its Code of Conduct." Detection runs through the confidential whistleblowing service, handled per the EU Whistleblowing Directive (2019/1937) by designated senior personnel; investigations are led by independent investigators separate from the prevention/detection management chain, with automatic recusal on conflicts.

Reporting governance: whistleblowing outcomes are reported to administrative, management and supervisory bodies; cases are tiered 1-4 by severity, with Tier 1 (crisis-level, e.g. business continuity or senior-management allegations) escalated to the Audit Committee, and the Management Group kept informed of all matters.

Training: the mandatory Code of Conduct eLearning course (onboarding plus repeat every two years) covers legal compliance, fair competition, fraud response, data safeguarding, insider information and zero tolerance for bribery/corruption. "The training program covers 100% of employees, including all functions-at-risk and members of administrative, management, and supervisory bodies." Related target: "Zero corruption and bribery cases reported" (Table G1.MDR-P, page 87).

Targets related to business conduct

Reference: page 87 (Table G1.MDR-P: Policies on business conduct and corporate culture).

This is a standalone 2025/2026-ESRS DR; the 2023 ESRS the report is prepared under has no equivalent numbered requirement (business conduct targets fell under MDR-T). The report is prepared under the 2023 ESRS with the 'quick-fix' reliefs of EU Delegated Regulation (EU) 2025/4812 (page 34).

Etteplan's G1.MDR-P policy table sets two explicit targets tied to its Code of Conduct policy on corruption and bribery prevention/detection:

• "100% Percent of people trained to Code of Conduct"
• "Zero corruption and bribery cases reported"

Progress against these is tracked through training-completion rates, whistleblowing case reviews and audit findings; "Internal audits in 2025 identified no major compliance breaches" (page 89).

Incidents of corruption or bribery

Reference: page 89.

"No confirmed incidents requiring remedy were reported during the reporting period." "In 2025, Etteplan recorded 0 convictions for violation of anti-corruption and anti-bribery laws in its operations or value chain." "Etteplan incurred EUR 0 in fines for such violations."

Actions supporting this outcome: Code of Conduct enforcement (all employees and partners); mandatory eLearning retaken every two years; Supplier Code of Conduct and Supplier Qualification Process for ethical screening of suppliers; the whistleblowing mechanism; annual ERM corruption/bribery risk reviews; and internal audits reporting to the Audit Committee. Time horizons: Code of Conduct training ongoing/2-yearly; supplier qualification ongoing; whistleblowing reviews, ERM risk assessments and internal audits annually.